TDCJ did not ensure that employees directly involved in evaluating Diversion grant applications and awarding those grants disclosed potential conflicts of interest. Specifically, for fiscal year 2018, the CJAD Director completed an annual conflict of interest disclosure dated October 12, 2017. However, none of the evaluation committee members for the fiscal years 2018 and 2019 (through February 28, 2019) grant applications or related procurement and contract management staff completed an annual conflict of interest disclosure.
The State of Texas Procurement and Contract Management Guide requires state agencies to assess actual and potential conflicts of interests for evaluation committee members and technical advisors to the committee. In addition, TDCJ’s chief financial officer, in an inter-office communication dated September 7, 2018, stated that division directors should identify staff directly involved in procurement or contract management within their division and require the identified individuals to sign a Disclosure of Potential Conflicts of Interest form annually.
Not ensuring that individuals involved in the grant evaluation and awarding process disclose potential and actual conflicts of interest limits TDCJ’s ability to identify and address conflicts in a timely manner and ensure the integrity of the evaluation process.
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